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United States Government Accountability Office:
GAO:
Report to Congressional Committees:
September 2011:
Chesapeake Bay:
Restoration Effort Needs Common Federal and State Goals and Assessment
Approach:
GAO-11-802:
GAO Highlights:
Highlights of GAO-11-802, a report to congressional committees.
Why GAO Did This Study:
The Chesapeake Bay, with its watershed in parts of six states and the
District of Columbia (watershed states), is an important economic and
natural resource that has been in decline. Over decades, federal
agencies and watershed states have entered into several agreements to
restore the bay, but its health remains impaired. In May 2009,
Executive Order 13508 established a Federal Leadership Committee, led
by the Environmental Protection Agency (EPA), and directed the
committee to issue a strategy by May 2010 to protect and restore the
Chesapeake Bay (the Strategy). GAO was directed by the explanatory
statement of the Consolidated Appropriations Act, 2008, to conduct
performance assessments of progress made on bay restoration, and this
first assessment examines (1) the extent to which the Strategy
includes measurable goals for restoring the bay that are shared by
stakeholders and actions to attain these goals; (2) the key factors,
if any, federal and state officials identified that may reduce the
likelihood of achieving Strategy goals and actions; and (3) agency
plans for assessing progress made in implementing the Strategy and
restoring bay health. GAO reviewed the Strategy, surveyed federal
officials, and interviewed watershed state officials and subject
matter experts.
What GAO Found:
The Strategy for Protecting and Restoring the Chesapeake Bay Watershed
includes 4 broad goals, 12 specific measurable goals with deadlines,
and 116 actions to restore the bay by 2025. To achieve the broad and
measurable goals, federal agencies, often in collaboration with the
watershed states and other entities, are responsible for accomplishing
the actions. However, not all stakeholders are working toward
achieving the Strategy goals. The watershed states are critical
partners in the effort to restore the bay, but state officials told
GAO that they are not working toward the Strategy goals, in part
because they view the Strategy as a federal document. Instead, most
state bay restoration work is conducted according to state commitments
made in a previous bay restoration agreement, the Chesapeake 2000
Agreement. Even though Strategy and Chesapeake 2000 Agreement goals
are similar to some degree, they also differ in some ways. For
example, both call for managing fish species, but the Strategy
identifies brook trout as a key species for restoration and the
Chesapeake 2000 Agreement does not. Federal and state officials said
it is critical that all stakeholders work toward the same goals. The
Federal Leadership Committee and the Chesapeake Bay Program—-a
restoration group established in 1983 that includes federal agencies
and watershed states—-created an action team in June 2010 to work
toward aligning bay restoration goals. The two groups have accepted a
process for developing common priorities and, if necessary, developing
a new restoration agreement by 2013.
Officials from the 11 agencies responsible for the Strategy that GAO
surveyed identified three key factors that may reduce the likelihood
of achieving Strategy goals and actions: a potential lack of
collaboration among stakeholders; funding constraints; and external
phenomena, such as climate change. State officials and subject matter
experts that GAO interviewed raised similar concerns. Federal
officials reported that some form of collaboration is needed to
accomplish the Strategy’s measurable goals and the vast majority of
its actions. In particular, federal-state collaboration is crucial,
with federal officials indicating that collaboration with at least one
state is necessary to accomplish 96 of the 116 actions in the 12
measurable goals. Federal officials also reported that funding
constraints could reduce the likelihood of accomplishing 69 of the
actions in 11 of the measurable goals. Furthermore, federal officials
reported that external phenomena could reduce the likelihood that 8 of
the measurable goals will be achieved.
The federal agencies have plans for assessing progress made in
implementing the Strategy and restoring bay health, but these plans
are limited or not fully developed, and it is unclear what indicators
will be used to assess bay health. Per the Strategy, the agencies plan
to create 2-year milestones for measuring progress made toward the
measurable goals, with the first milestones covering 2012 and 2013.
However, establishing milestones for an entire effort can improve the
chances the effort can be accomplished efficiently and on time. Also,
the Strategy states that the Federal Leadership Committee will develop
a process for implementing adaptive management-—in which agencies
evaluate the impacts of restoration efforts and use the results to
adjust future actions—-but agency officials told GAO they are still
developing this process. Moreover, there are now two groups that plan
to assess bay health. The Strategy calls for the Federal Leadership
Committee to coordinate with the watershed states to align these
assessments. However, the status of this alignment is unclear, and if
these groups use different indicators to assess bay health, confusion
could result about the overall message of progress made.
What GAO Recommends:
GAO recommends that EPA work with federal and state stakeholders to
develop common goals and clarify plans for assessing progress. In
commenting on a draft of this report, EPA generally agreed with the
recommendations.
View [hyperlink, http://www.gao.gov/products/GAO-11-802]. For more
information, contact David C. Trimble at (202) 512-3841 or
trimbled@gao.gov.
[End of section]
Contents:
Letter:
Background:
Restoration Strategy Includes Measurable Goals and Actions to Achieve
Them, but Not All Bay Restoration Stakeholders Are Working toward
These Goals:
Federal and State Officials Identified Three Key Factors That May
Reduce the Likelihood of Achieving Strategy Goals and Actions:
Agency Plans for Assessing Progress on Implementing the Strategy and
Restoring Bay Health Are Limited or Not Fully Developed, and It Is
Unclear What Indicators Will Be Used to Assess Progress on Bay Health:
Conclusions:
Recommendations for Executive Action:
Agency Comments, Third-Party Views, and our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Survey Questions:
Appendix III: Collaboration Needed between Federal Agencies and
Watershed States to Accomplish Strategy Actions:
Appendix IV: Chesapeake Bay Program Adaptive Management Decision
Framework:
Appendix V: Comments from the Environmental Protection Agency:
Appendix VI: Comments from the Department of Homeland Security:
Appendix VII: Comments from the Department of the Interior:
Appendix VIII: Comments from the State of New York:
Appendix IX: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Strategy Broad Goals and Their Associated Measurable Goals:
Table 2: Number of the 116 Strategy Actions for Which Watershed State
Participation Is Necessary to Accomplish Them, as Reported by Federal
Officials:
Table 3: Number of Actions for Which Each Federal Agency Reported That
Participation from a Watershed State Was Necessary to Accomplish the
Action:
Figures:
Figure 1: Chesapeake Bay Watershed:
Figure 2: The Recover Habitat Broad Goal and Its Measurable Goals and
Actions:
Figure 3: Extent of Collaboration Needed between Federal Agencies and
Watershed States to Accomplish Strategy Actions:
Abbreviations:
EPA: Environmental Protection Agency
TMDL: total maximum daily load:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
September 15, 2011:
The Honorable Jack Reed:
Chairman:
The Honorable Lisa Murkowski:
Ranking Member:
Subcommittee on Interior, Environment, and Related Agencies:
Committee on Appropriations:
United States Senate:
The Honorable Mike Simpson:
Chairman:
The Honorable Jim Moran:
Ranking Member:
Subcommittee on Interior, Environment, and Related Agencies:
Committee on Appropriations:
House of Representatives:
The Chesapeake Bay is the nation's largest estuary, and its watershed
spans 64,000 square miles across six states--Delaware, Maryland, New
York, Pennsylvania, Virginia, and West Virginia--and the District of
Columbia, which we collectively refer to as watershed states. The bay
provides habitat for a wide variety of animals and plants and supports
local and regional economies. However, concerns about the bay's
overall health surfaced as early as the 1930s, and signs of
deterioration--declines in water clarity, dwindling oyster
populations, and degraded habitat--became even more apparent in the
1950s and 1960s. In the 1970s and early 1980s, the Environmental
Protection Agency (EPA) found that the primary causes for the decline
in the bay's condition were excess nutrients from agriculture, such as
nitrogen and phosphorus; population growth; and discharges from sewage
treatment plants. More recently, a 2009 bay health assessment found
that despite small improvements in certain areas, the bay continues to
have poor water quality, low populations of many fish and shellfish
species, and degraded habitats.[Footnote 1]
Responding to public outcry about the degraded state of the bay, EPA
and several watershed states first entered into an agreement in 1983
to restore and protect the bay. Through this agreement, these states
and EPA began to work together as the Chesapeake Bay Program, a
partnership that directs and conducts the restoration of the bay at
the federal, state, and local levels, and also includes academic
institutions and nonprofit organizations. Since then, EPA and several
watershed states have entered into additional bay restoration
agreements. The most recent agreement, Chesapeake 2000, set out an
agenda and goals to guide restoration and protection efforts from 2000
through 2010 and beyond, and each of the watershed states made
commitments to it. However, in October 2005, we reported that the
success of the restoration effort had been undermined, in part by the
lack of a comprehensive, coordinated implementation strategy and
integrated approaches to measure overall progress.[Footnote 2] We
recommended that EPA should, among other things, work with the Bay
Program to develop an overall, coordinated implementation strategy and
develop and implement an integrated approach to assess overall
restoration progress. Subsequently, the explanatory statement
accompanying the Consolidated Appropriations Act, 2008, directed EPA,
as the lead federal agency in the Bay Program, to immediately
implement all of our recommendations and to develop a Chesapeake Bay
action plan for the remaining years of the Chesapeake 2000 Agreement.
[Footnote 3] In response, the Bay Program submitted a report to
Congress describing the steps it took to implement our
recommendations. We testified in July 2008 that the Bay Program had
taken positive steps, such as identifying key indicators for measuring
bay health and restoration progress, to improve the coordination and
management of the restoration effort, but that additional actions were
needed.[Footnote 4]
In May 2009, the administration stated that, despite decades of
efforts by federal agencies, state and local governments, and other
interested parties, bay restoration was not expected for many years.
As a result, the President issued Executive Order 13508 to take
further actions to restore and protect the bay.[Footnote 5] The
executive order established a Federal Leadership Committee to oversee
the development and coordination of federal restoration programs and
activities and called for the development by May 2010 of a strategy to
protect and restore the bay. The Federal Leadership Committee is
chaired by the EPA Administrator, and includes senior representatives
from the U.S. Departments of Agriculture, Commerce, Defense, Homeland
Security, the Interior, and Transportation. The executive order noted
that although the federal government should assume a strong leadership
role in the restoration of the bay, success depends on a collaborative
effort involving each watershed state, local governments, and other
organizations. The order stated that the committee shall consult
extensively with the watershed states in the development of the
strategy to ensure that federal actions are closely coordinated with
actions by state and local agencies and that resources; authorities;
and expertise of federal, state, and local agencies are used as
efficiently as possible. The committee issued the Strategy for
Protecting and Restoring the Chesapeake Bay Watershed (the Strategy)
in May 2010.[Footnote 6]
The explanatory statement accompanying the Consolidated Appropriations
Act, 2008, directed EPA to develop a Chesapeake Bay action plan and
GAO to conduct periodic performance assessments of progress made on
this plan. Because EPA officials told us that the Strategy is the
current plan to restore the bay, as agreed with your offices, this
first performance assessment in response to the mandate focuses on the
Strategy. This report examines (1) the extent to which the Strategy
includes measurable goals for restoring the Chesapeake Bay that are
shared by stakeholders and actions to attain these goals; (2) the key
factors, if any, federal and state officials identified that may
reduce the likelihood of achieving Strategy goals and actions; and (3)
agency plans for assessing progress made in implementing the Strategy
and restoring bay health.
To determine the extent to which the Strategy includes measurable
goals for restoring the Chesapeake Bay that are shared by stakeholders
and actions to attain these goals, we reviewed the Strategy to
understand its structure and identify goals and actions. For the
actions, we focused on the 116 actions that are designed to lead
directly to the Strategy's goals. We also reviewed previous bay
restoration agreements, such as Chesapeake 2000, to identify previous
bay restoration goals. In addition, we interviewed federal and
watershed state officials and representatives of organizations
involved with bay restoration to gain an understanding of the Strategy
and bay restoration efforts. To examine the key factors federal and
state officials identified that may reduce the likelihood of achieving
Strategy goals and actions, we conducted an electronic survey of the
11 federal agencies responsible for creating and implementing the
Strategy: EPA; the Department of Agriculture's Forest Service and
Natural Resources Conservation Service; the Department of Commerce's
National Oceanic and Atmospheric Administration; the Department of
Defense's Navy and U.S. Army Corps of Engineers; the Department of
Homeland Security; the Department of the Interior's Fish and Wildlife
Service, National Park Service, and U.S. Geological Survey; and the
Department of Transportation. In addition, we interviewed officials
from each watershed state to obtain their views on factors that could
reduce the likelihood of achieving Strategy goals and actions. We also
interviewed a nonprobability sample of members of academia with bay-
related subject matter expertise. Because we used a nonprobability
sample, the information obtained from these interviews is not
generalizable to other members of academia with bay-related expertise.
However, these interviews provided us with information on these
individuals' views on the attainability of the Strategy's measurable
goals. We selected these experts primarily through GAO's prior
Chesapeake Bay work. To examine what plans are in place to assess
progress made in implementing the Strategy and restoring the bay, we
reviewed the Strategy and Strategy-related assessment documents and
interviewed federal officials. A complete description of our scope and
methodology is in appendix I. The questions from our electronic survey
of federal agency officials are available in appendix II.
We conducted this performance audit from August 2010 to September 2011
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.
Background:
The Chesapeake Bay is the nation's largest estuary, measuring nearly
200 miles long and 35 miles wide at its widest point. The bay's
watershed covers 64,000 square miles and, as shown in figure 1, spans
parts of six states--Delaware, Maryland, New York, Pennsylvania,
Virginia, and West Virginia--and the District of Columbia. The
Chesapeake Bay tributaries and watershed make up one of the most
biologically productive systems in the world, with more than 3,600
species of plants, fish, and wildlife. The ecosystem also provides a
variety of benefits to the almost 17 million people who live in the
watershed, such as protecting drinking water, minimizing erosion and
flood events related to stormwater runoff, and numerous recreational
opportunities.
Figure 1: Chesapeake Bay Watershed:
[Refer to PDF for image: U.S. map]
The U.S. map displays an inset map of the location of the Chesapeake
Bay watershed in the following states:
Delaware;
District of Columbia;
Maryland;
New York;
Pennsylvania;
Virginia;
West Virginia.
The following rivers are depicted as being part of the watershed:
James River;
Patuxent River;
Potomac River;
Rappahannock River;
Susquehanna River.
Sources: EPA and GAO.
[End of figure]
Over time, however, the bay's ecosystem has deteriorated. As mentioned
previously, water quality has deteriorated primarily because of excess
amounts of nutrients entering the bay, which lead to the damage of
animal and plant populations. According to a 2010 EPA bay document,
the single largest source of these pollutants is agricultural runoff.
In addition, population growth and development have further stressed
the ecosystem.[Footnote 7] The population of the bay watershed has
doubled since 1950, adding approximately 1.5 million people every
decade, and is expected to approach 20 million by 2030. With this
population increase, open spaces are being paved and developed,
creating hardened surfaces that send an increasing amount of polluted
stormwater into the bay and its rivers. Furthermore, sediment in the
bay, stemming in part from agriculture and urban lands, has had
harmful effects on the bay and its watershed, such as preventing light
from penetrating to the leaves and stems of underwater grasses that
provide habitat and stability to the bay.
The deterioration of the bay's ecosystem has been the cause for a
great deal of public and political attention. Efforts to manage the
bay's ecosystem and protect its living resources began as early as the
1930s and continue today. These efforts include the following:
* In 1980, Maryland and Virginia, later joined by Pennsylvania,
established the Chesapeake Bay Commission to serve as an advisory body
on the Chesapeake Bay to their state legislatures and as a liaison to
Congress.
* In 1983, Maryland, Virginia, Pennsylvania, the District of Columbia,
EPA, and the Chair of the Chesapeake Bay Commission signed the first
Chesapeake Bay agreement, formalizing the Chesapeake Bay Program. The
Bay Program is a partnership of federal agencies, states, academic
institutions, and others that directs and conducts the restoration of
the bay. EPA represents the federal government within the Bay Program
and supports the partnership through its Chesapeake Bay Program
Office. The signatories to the agreement reaffirmed their commitment
to restore the bay in 1987 and again in 1992.
* In 2000, the Bay Program signatories signed the most current
agreement, known as the Chesapeake 2000 Agreement. It outlined five
broad goals and 102 commitments for the restoration effort. Delaware,
New York, and West Virginia later signed a memorandum of understanding
agreeing to work cooperatively to achieve the pollution reduction
targets identified to meet the water quality goals in the agreement.
The end dates in the Chesapeake 2000 Agreement commitments largely
expired in 2010 or earlier. Some of these commitments have been
renewed, but many have not.
* Also in 2000, Congress passed the Estuaries and Clean Waters Act,
which directed EPA to take various actions to coordinate the
Chesapeake Bay Program and to support the implementation of the
Chesapeake 2000 Agreement. The act also required other federal
agencies with facilities in the bay watershed to participate in
restoration efforts.
In 2005, we examined the Bay Program's implementation of the
Chesapeake 2000 Agreement to determine, among other things, the extent
to which appropriate measures for assessing restoration progress had
been established and how effectively the effort was being coordinated
and managed.[Footnote 8] Among other things, we found that the Bay
Program lacked a comprehensive, coordinated implementation strategy to
better enable it to achieve the goals outlined in the agreement and
assessment reports did not effectively communicate the status of the
bay's health. We made several recommendations to the Administrator of
EPA, including to instruct the Chesapeake Bay Program Office to (1)
work with the Bay Program to develop a comprehensive, coordinated
implementation strategy and (2) to develop and implement an integrated
approach to assess overall restoration progress. EPA took several
actions to incorporate our recommendations, such as reducing more than
100 bay health and restoration indicators into three indices of
ecosystem health and five indices of restoration effort.
Subsequently, in the explanatory statement of the Consolidated
Appropriations Act, 2008, Congress directed EPA to implement
immediately all the recommendations in our report, and to develop a
Chesapeake Bay action plan for the remaining years of the Chesapeake
2000 Agreement. The Bay Program responded to the Consolidated
Appropriations Act with a July 2008 report to Congress that described
the program efforts to implement our recommendations, and the
development of an action plan for the Chesapeake Bay.[Footnote 9] We
testified in July 2008 that the Bay Program had taken several actions
in response to our recommendations, such as developing a strategic
framework to unify planning documents and identify how it will pursue
its goals.[Footnote 10] However, we also testified that additional
actions were needed before the program had the comprehensive,
coordinated implementation strategy we recommended.
On May 12, 2009, the President issued Executive Order 13508,
Chesapeake Bay Protection and Restoration. The executive order noted
that despite significant efforts, water pollution in the Chesapeake
Bay prevents the attainment of state water quality standards, and that
restoration of the bay was not expected for many years. It also stated
that bay restoration will require restoring habitat and living
resources, conserving lands, and improving management of natural
resources. The executive order established the Federal Leadership
Committee and required the committee to develop a strategy to guide
efforts to restore and protect the bay. According to the order, the
strategy was to define environmental goals for the Chesapeake Bay and
describe the specific programs and strategies to be implemented, among
other things. The Federal Leadership Committee published the Strategy
in May 2010.
On December 29, 2010, EPA established a total maximum daily load
(TMDL)--a "pollution diet"--for the Chesapeake Bay and the region's
streams, creeks, and rivers in response to consent decrees stemming
from litigation against the agency.[Footnote 11] A TMDL is the
calculation of the maximum amount of pollution a body of water can
receive and still meet state water quality standards, and the Clean
Water Act requires the creation of TMDLs for water bodies not
attaining their water quality standards. The bay TMDL was also
influenced by a settlement resolving a lawsuit filed against EPA in
which the Chesapeake Bay Foundation and other entities alleged that
EPA had failed to comply with the Clean Water Act by not taking steps
to achieve some of the Chesapeake 2000 Agreement goals.[Footnote 12]
The bay TMDL is the largest ever developed by EPA, encompassing the
entire 64,000-square-mile watershed. It identifies the necessary
pollution reductions from major sources of nitrogen, phosphorus, and
sediment across the District of Columbia and large sections of
Delaware, Maryland, New York, Pennsylvania, Virginia, and West
Virginia, and sets pollution limits necessary to meet water quality
standards in the bay and its tidal rivers. To implement the TMDL, EPA
is taking steps to ensure that each watershed state develops a
Watershed Implementation Plan that details how and when it will meet
pollution allocations laid out in the TMDL. Each watershed state
submitted its phase one implementation plan to EPA for review in
November 2010, and must submit a phase two plan by March 2012 and a
phase three plan in 2017.[Footnote 13] If EPA concludes that a
watershed state has taken insufficient steps to implement its
Watershed Implementation Plans or to reduce pollution, the agency is
prepared to take one or more actions, including expanding coverage of
wastewater permits to sources that are currently unregulated.[Footnote
14] The TMDL marks a change from the historic nature of the effort,
which was based primarily on stakeholder agreements.
Restoration Strategy Includes Measurable Goals and Actions to Achieve
Them, but Not All Bay Restoration Stakeholders Are Working toward
These Goals:
The Strategy articulates broad restoration goals, specific measurable
goals, and actions to achieve those goals. Specifically, it includes 4
broad goals, 12 measurable goals with deadlines, and 116 actions to
restore the bay by 2025.[Footnote 15] The 4 broad goals--restore clean
water, recover habitat, sustain fish and wildlife, and conserve land
and increase public access--are identified in the Strategy as the most
essential priorities for a healthy Chesapeake system. To meet these 4
broad goals, the Strategy identifies 12 measurable goals that contain
numeric descriptions of results--or outcomes--to be achieved by 2025
(see table 1). For example, to help meet the recover habitat broad
goal, the Strategy identifies a fish passage measurable goal to
restore historical fish migratory routes by opening 1,000 additional
stream miles by 2025, with restoration success indicated by the
presence of river herring, American shad, or American eel. The
Strategy also identifies four supporting strategies--expand citizen
stewardship, develop environmental markets, respond to climate change,
and strengthen science--that were designed, in part, to provide cross-
cutting support for attaining the Strategy's broad goals.[Footnote 16]
Table 1: Strategy Broad Goals and Their Associated Measurable Goals:
Strategy broad goals: Restore clean water;
Reduce nutrients, sediment, and other pollutants to meet bay water
quality goals for dissolved oxygen, clarity, and chlorophyll-a and
toxic contaminants;
Strategy measurable goals:
* Water quality. Meet water quality standards for dissolved oxygen,
clarity/underwater grasses, and chlorophyll-a in the bay and tidal
tributaries by implementing 100 percent of pollution reduction actions
for nitrogen, phosphorus, and sediment no later than 2025, with 60
percent of segments attaining standards by 2025.
* Stream restoration. Improve the health of streams so that 70 percent
of sampled streams throughout the Chesapeake watershed rate three,
four, or five (corresponding to fair, good, or excellent) as measured
by the Index of Biotic Integrity by 2025.
* Agricultural conservation. Work with agricultural producers to apply
new conservation practices on 4 million acres of agricultural working
lands in high-priority watersheds by 2025 to improve water quality in
the Chesapeake Bay and its tributaries.
Strategy broad goals: Recover habitat;
Restore a network of land and water habitats to support priority
species and to afford other public benefits, including water quality,
recreational uses, and scenic value across the watershed;
Strategy measurable goals:
* Wetlands. Restore 30,000 acres of tidal and nontidal wetlands and
enhance the function of an additional 150,000 acres of degraded
wetlands by 2025.
* Forest buffer. Restore riparian forest buffers to 63 percent, or
181,440 miles, of the total riparian miles (stream bank and shoreline
miles) in the bay watershed by 2025.
* Fish passage. Restore historical fish migratory routes by opening
1,000 additional stream miles by 2025, with restoration success
indicated by the presence of river herring, American shad, or American
eel.
Strategy broad goals: Sustain fish and wildlife;
Sustain healthy populations of fish and wildlife, which contribute to
a resilient ecosystem and vibrant economy;
Strategy measurable goals:
* Oyster. Restore native oyster habitat and populations in 20
tributaries out of 35 to 40 candidate tributaries by 2025.
* Blue crab. Maintain sustainable blue crab interim population target
of 200 million adults (1+ years old) in 2011 and develop a new
population rebuilding target for 2012-2025.
* Brook trout. Restore naturally reproducing brook trout populations
in headwater streams by improving 58 subwatersheds from "reduced"
classification (10-50 percent of habitat lost) to "healthy" (less than
10 percent of habitat lost) by 2025.
* Black duck. Restore a 3-year average wintering black duck population
in the bay watershed of 100,000 birds by 2025.
Strategy broad goals: Conserve land and increase public access;
Conserve landscapes treasured by citizens to maintain water quality
and habitat; sustain working forests, farms, and maritime communities;
and conserve lands of cultural, indigenous, and community value.
Expand public access to the bay and its tributaries through existing
and new local, state, and federal parks; refuges; reserves; trails;
and partner sites;
Strategy measurable goals:
* Land conservation. Protect an additional 2 million acres of land
throughout the watershed currently identified as high conservation
priorities at the federal, state, or local level by 2025, including
695,000 acres of forest land of highest value for maintaining water
quality.
* Public access. Increase public access to the bay and its tributaries
by adding 300 new public access sites by 2025.
Source: GAO analysis of the Strategy.
[End of table]
In turn, the 12 measurable goals were designed to be achieved through
the accomplishment of 116 actions. These actions describe activities
to be taken by federal agencies, often in collaboration with the
watershed states and other entities. For example, one action in the
fish passage measurable goal--remove stream barriers and provide fish
passage--calls for two federal agencies to work with state and local
partners to, among other things, prioritize stream barriers that
inhibit fish passage. Figure 2 illustrates the relationship of the
recover habitat broad goal and its measurable goals and selected
actions. Federal officials we surveyed reported that about 95 percent
of the actions in the Strategy could definitely or probably be
accomplished, assuming current and expected budget and staff levels,
and generally agreed that accomplishing the actions will lead to the
achievement of the measurable and broad goals by 2025.
Figure 2: The Recover Habitat Broad Goal and Its Measurable Goals and
Actions:
[Refer to PDF for image: illustration]
Broad Goals: Recover habitat;
Restore a network of land and water habitats to support priority
species and to afford other public benefits, including water quality,
recreational uses, and scenic value across the watershed.
Measurable Goals:
* Wetlands measurable goal: Restore 30,000 acres of tidal and nontidal
wetlands and enhance the function of an additional 150,000 acres of
degraded wetlands by 2025.
Actions:
1. Restore and protect priority Chesapeake marshes.
2. Increase incentives for wetland restoration and enhancement on
private lands.
3. Strengthen federal coordination on permits that impact wetlands.
* Forest buffer measurable goal: Restore riparian forest buffers to 63
percent, or 181,440 miles, of the total riparian miles (stream bank
and shoreline miles) in the bay watershed by 2025.
Actions:
1. Accelerate application of Conservation Reserve Enhancement Program
to achieve state goals for riparian forest buffer adoption.
2. Restore forest buffers in priority watersheds.
3. Explore alternative payment mechanisms for incentivizing the
installation of targeted riparian forest buffers.
4. Enhance technical capacity for riparian buffer restoration.
* Fish passage measurable goal: Restore historical fish migratory
routes by opening 1,000 additional stream miles by 2025, with
restoration success indicated by the presence of river herring, American
shad, or American eel.
Actions:
1. Remove stream barriers and provide fish passage.
2. Document the return of fish to opened stream reaches.
Source: GAO analysis of the Strategy.
Note: The recover habitat broad goal contains a total of 24 actions.
In addition to the 9 actions listed, an additional 15 actions are
identified in the Strategy to generally support the recover habitat
broad goal and measurable goals.
[End of figure]
Even though the federal agencies have developed a plan with measurable
goals and actions, we found that not all stakeholders are working
toward achieving these measurable goals. The watershed states are
critical partners in the effort to restore the bay, but officials from
each of the states told us that even though their states are
conducting bay restoration work, their states are not working toward
the Strategy goals, in some cases because they view the Strategy as a
federal document. As of July 2011, the watershed states have not
committed to the Strategy. Instead, most watershed state officials
told us that their bay restoration work is conducted according to
their commitments to the Chesapeake 2000 Agreement. Federal and state
officials told us that Strategy and Chesapeake 2000 Agreement goals
are similar to some degree. For example, both identify phosphorus and
nitrogen reduction as necessary steps for improving water quality.
However, the goals also differ in some ways. For example, both the
Strategy and the Chesapeake 2000 Agreement call for managing fish
species, but the Strategy identifies brook trout as a key species for
targeted restoration efforts and the Chesapeake 2000 Agreement does
not. Both agreements also have oyster restoration goals, but the
Strategy identifies a number of tributaries to be restored and the
Chesapeake 2000 Agreement focuses on an increase in the number of
oysters in the bay.
In addition, officials from most of the watershed states told us that
they are focused on accomplishing tasks associated with the bay TMDL,
such as developing their Watershed Implementation Plans. Officials
from several federal agencies also observed that the watershed states
are fully occupied with efforts to comply with the TMDL. The bay TMDL
was incorporated into the Strategy's water quality broad goal, which
means that the pollution reduction steps that the states plan to
implement in order to achieve the TMDL should contribute to the
accomplishment of that Strategy goal. Similarly, each watershed state
has identified pollution reduction activities in its phase one
Watershed Implementation Plan that could contribute incidentally to
other Strategy goals, even though the activities were created to
achieve water quality standards and development on them began before
the publication of the Strategy. For example, each watershed state has
identified wetland restoration as part of its phase one Watershed
Implementation Plan, and the Strategy's recover habitat goal contains
a measurable goal to restore wetlands. However, it is unclear whether
the watershed states' wetland restoration activities will be
sufficient to help meet the Strategy's measurable goal for wetlands.
For example, not all of the Watershed Implementation Plans identify
the total wetland acreage to be restored.
It is important for all partners in the restoration effort to be
working toward the same goals. We have previously reported that
identifying common goals is a key characteristic of successful
collaborative efforts.[Footnote 17] Specifically, we found that having
common goals, among other factors, can help lead to increased
participation and cooperation among groups involved in a collaborative
effort and to improve natural resource conditions. Several of the
federal and state officials we interviewed also said that they believe
it is critical that all stakeholders in the bay restoration effort are
working toward the same goals and following the same plan. For
example, a federal official told us that alignment between the
Strategy and state actions would allow for the most integrated,
efficient way of restoring the bay. In addition, a state official told
us that the lack of alignment leads to a lack of support for the
Strategy from the states.
In June 2010, the Federal Leadership Committee and the Bay Program
created an alignment action team to work toward aligning Strategy
restoration efforts with those of the Bay Program, including
Chesapeake 2000 Agreement efforts. In addition to the lack of common
goals, the team also identified several other reasons for alignment,
including restoration tracking and communication difficulties caused
by stakeholders focusing on different goals, and that limited
resources are being diverted to addressing organizational confusion
rather than implementation of bay restoration efforts. In January
2011, the alignment action team proposed developing a new restoration
plan to provide a blueprint for the future of the restoration effort
that will align Strategy and Bay Program goals. The Federal Leadership
Committee and Bay Program have not yet agreed to develop this new
plan. Under a process that was agreed to by both groups, they will
work within preexisting Bay Program groups, called Goal Implementation
Teams, to, among other things, refine priorities and areas of
programmatic focus, guided by the Chesapeake 2000 Agreement and the
Strategy. As part of this process, if the groups decide to negotiate a
new agreement, it would not be negotiated until 2013, according to a
July 2011 Bay Program document.
Federal and State Officials Identified Three Key Factors That May
Reduce the Likelihood of Achieving Strategy Goals and Actions:
Officials we surveyed from the 11 federal agencies responsible for the
Strategy identified three key factors that may reduce the likelihood
of achieving Strategy goals and actions, and state officials and
subject matter experts we interviewed raised similar concerns. We
identified as key those factors most frequently identified by federal
officials: collaboration, funding constraints, and external phenomena.
Collaboration. First, most of the federal officials we surveyed
indicated that a potential lack of collaboration among stakeholders
could reduce the likelihood of achieving Strategy goals and actions.
They reported that some form of collaboration is necessary to
accomplish all of the Strategy's measurable goals and the vast
majority of its actions. This collaboration could be between federal
agencies, federal and state agencies, or federal agencies and other
entities. In particular, federal-state collaboration is crucial to
accomplishing the Strategy's goals and actions. In their survey
responses, federal officials indicated that collaboration with at
least one state is necessary to accomplish 96 of the 116 actions in
all 12 of the measurable goals. For example, the Strategy's measurable
goal for blue crab calls in part for the development of a new blue
crab population target for 2012 through 2025, but a federal official
reported that setting such a target is a matter of state, not federal,
jurisdiction. The official indicated that the federal agency
responsible for the action will facilitate state agreement on a new
target, but that securing agreement is in the hands of the states, not
the agencies. Table 2 shows the number of actions that, according to
federal officials' survey responses, need state participation in order
to be accomplished. Appendix III provides additional information on
the extent to which collaboration between federal agencies and
watershed states is needed to accomplish strategy actions.
Table 2: Number of the 116 Strategy Actions for Which Watershed State
Participation Is Necessary to Accomplish Them, as Reported by Federal
Officials:
State: Maryland;
Number of actions: 94.
State: Virginia;
Number of actions: 90.
State: Pennsylvania;
Number of actions: 70.
State: New York;
Number of actions: 65.
State: Delaware;
Number of actions: 64.
State: West Virginia;
Number of actions: 64.
State: District of Columbia;
Number of actions: 52.
Source: GAO analysis of survey responses.
Note: If more than one agency identified the same state as necessary
for the same action, that action was counted only once for that state.
The maximum number of actions for which each state's participation
could be necessary is 116.
[End of table]
Even though the watershed states are critical partners in the
restoration effort, most watershed state officials told us that they
are generally unaware of what federal agencies may require of them to
implement the Strategy. Specifically, officials from six of the seven
watershed states noted that they were not aware of the extent to which
federal agencies needed their participation when we told them the
number of actions federal officials had identified that would need
state participation to be accomplished. Some federal and state
officials noted that their agencies are working on bay issues through
the Goal Implementation Teams. Some of these groups are discussing the
Strategy, but, according to a January 2011 Bay Program memorandum,
specific state contributions toward the measurable goals have not been
determined.
In addition to the need for federal-state collaboration, collaboration
between two or more federal agencies is necessary to accomplish 40 of
the actions in 8 of the measurable goals, according to our survey
results. Some federal officials told us that collaboration among
federal agencies increased during the development and implementation
of the Strategy. According to some federal officials, this has
resulted in closer relationships between some agencies and more tools
and perspectives being used to restore the watershed. Other officials
expressed concern that recent bay restoration meetings have focused
largely on bay water quality issues with less time spent on other
restoration activities and needs, such as restoring brook trout
populations or increasing public access to the bay.
Funding constraints. The second key factor stakeholders identified
that may reduce the likelihood of achieving Strategy goals and actions
is funding constraints. Specifically, in their survey responses,
federal officials indicated that funding constraints at the federal
and state levels, and among other partners, such as academic
institutions, could reduce the likelihood of accomplishing 69 of the
actions in 11 of the measurable goals. Some federal officials told us
that increased federal funding will be critical to accomplishing the
actions and measurable goals. For example, a federal official reported
that achieving the measurable goal for land conservation is contingent
upon increased federal funding, in part because the recent economic
crisis has reduced state land conservation funding. State land
conservation funding is necessary to accomplish several land
conservation actions in the Strategy, according to federal survey
responses. In addition, another federal official told us that the
measurable goal of restoring oyster habitat and populations has been
delayed because of late allocations of fiscal year 2011 funding.
Officials from each of the watershed states also told us that funding
constraints may reduce their ability to restore the bay. For example,
officials from one state told us that their state needs about $38
billion in wastewater treatment infrastructure to reduce water
pollution, and noted that overall challenging fiscal circumstances
mean the state has a limited capacity to conduct additional bay
restoration activities. Similarly, officials from another state told
us that their state has experienced budget cuts in recent years and
that funding constraints could reduce the likelihood of conducting
restoration activities. In addition, fish passage experts we
interviewed told us that states will have to contribute significant
funding for stream restoration projects if the measurable goal of
increasing fish passages is to be achieved. However, states' current
fiscal conditions may reduce their ability to do so.
External phenomena. The third key factor that may reduce the
likelihood of achieving Strategy goals and actions, according to
federal agency survey responses and subject matter experts, is
external phenomena that are outside the control of the agency, such as
climate change or population growth. Even though the Strategy
addresses some external phenomena, for example, by including a
supporting strategy for responding to climate change, federal
officials told us that effects beyond what was planned for in
developing the Strategy could affect the likelihood of achieving the
measurable goals. Specifically, federal officials reported that
external phenomena could reduce the likelihood that 8 of the
measurable goals will be achieved even if all of the actions in those
measurable goals were accomplished. For example, according to one
federal agency's survey response and a subject matter expert we
interviewed, both climate change and increased development in the
watershed could reduce the likelihood of achieving the measurable goal
to restore naturally reproducing brook trout populations in headwater
streams by 2025. The brook trout expert explained that climate change
may affect stream temperature, which can result in a loss of brook
trout. In addition, the expert told us that an increase in the amount
of impervious surfaces in the watershed as a result of development can
increase polluted runoff and degrade habitat, resulting in a loss of
brook trout. As another example, insufficient or degraded breeding
habitat outside of the bay watershed could reduce the likelihood of
achieving the measurable goal of restoring a 3-year average wintering
black duck population of 100,000 birds by 2025, according to this
agency's survey response and two subject matter experts.
Agency Plans for Assessing Progress on Implementing the Strategy and
Restoring Bay Health Are Limited or Not Fully Developed, and It Is
Unclear What Indicators Will Be Used to Assess Progress on Bay Health:
The Strategy calls for the federal agencies to, among other things,
develop 2-year milestones, an adaptive management process, and annual
progress reports to assess progress made in implementing the Strategy
and restoring the health of the bay. However, the milestone
development plan is limited, plans for adaptive management and the
annual progress report are not fully developed, and it is unclear what
indicators will be used to assess progress on bay health.
Milestone Development Plan Is Limited:
The federal agencies do not plan to develop milestones for the entire
Strategy period. Per the Strategy, the agencies plan to create
milestones every 2 years for measuring progress made toward the
measurable goals, with the first set of 2-year milestones to cover
calendar years 2012 and 2013. However, setting the milestones every 2
years allows for the possibility of moving the target date to the next
2-year milestone period if the milestone could not be met in those 2
years, thereby prolonging the time it will take to meet the Strategy's
goals. In addition, without a blueprint of milestones for the entire
restoration effort, it is unclear how the agencies will determine
whether they are on track to achieve the 12 measurable goals and 4
broad goals by 2025. Some restoration activities may not result in
immediate improvements to the health of the bay, and it may be
reasonable to expect slower progress toward a measurable goal
initially, with faster progress made after a number of years into the
restoration effort. On the other hand, some restoration activities may
be easier to accomplish than others, and it may be reasonable to
expect faster progress made toward a measurable goal initially and
slower progress made after a number of years into the effort. By
identifying a blueprint of milestones for the entire restoration
effort, the agencies can show when the actions are expected to result
in progress toward the measurable goals, determine whether these
actions are having their intended result, and make changes to these
actions if needed. We have reported that establishing milestones for
an entire effort can improve the chances the effort can be
accomplished efficiently and on time and provide decision makers with
an indication of the incremental progress the agency expects to make
in achieving results.[Footnote 18]
Plans for Adaptive Management and Annual Progress Report Are Not Fully
Developed:
The Federal Leadership Committee has neither developed an adaptive
management process nor identified what performance data it will use to
gauge progress in the annual progress report. The Strategy states that
the Federal Leadership Committee will develop a process for
implementing adaptive management, but officials from EPA and other
committee agencies told us that they are still developing this
process. According to EPA officials, the Federal Leadership Committee
agreed to the seven-step adaptive management decision framework that
the Bay Program adopted in May 2011. This framework, however, was
developed for the Bay Program and does not include clear linkages to
the Strategy actions and measurable goals. It is unclear how it will
be used by the Federal Leadership Committee agencies to adaptively
manage Strategy actions and meet Strategy goals (see appendix IV). In
August 2011, EPA officials noted that a fully developed adaptive
management process is needed. A fully developed adaptive management
process should allow the agencies to evaluate whether Strategy actions
are leading to the measurable goals and, if needed, adjust their
efforts. This approach includes assessing the problem, designing a
plan that includes measurable management objectives, monitoring the
impacts of the selected management actions, and evaluating and using
the results to adjust management actions. In 2004, the National
Research Council defined adaptive management as a process that
promotes flexible decision making in the face of uncertainties, as
outcomes from management actions and other events become better
understood. In 2011, the National Research Council looked at the
Chesapeake Bay Program's nutrient reduction program and found that
neither EPA nor the watershed states exhibit a clear understanding of
how adaptive management might be applied in pursuit of the Bay
Program's water quality goals.[Footnote 19] We believe a fully
developed adaptive management process is essential to Strategy success
because the agencies can improve bay restoration efforts by learning
from management outcomes. We have previously reported that the lack of
a well-developed adaptive management process impaired the success of
collaborative restoration efforts, such as restoring the South Florida
ecosystem and restricting bison movement in Montana to prevent the
spread of disease.[Footnote 20]
The Strategy also calls for the Federal Leadership Committee to
develop an annual progress report that would, in part, assess the
progress made in implementing the Strategy in the previous year.
According to EPA officials, the agencies will report progress on the
actions quarterly to the committee, and the agencies will use these
quarterly reports to develop an annual progress report that will be
issued to the public. In a fiscal year 2011 action plan, the Federal
Leadership Committee identified which federal agency is responsible
for implementing each Strategy action and what the agencies are
expected to accomplish in that year.[Footnote 21] The committee has
also separately designated a lead federal agency for assessing
progress toward each measurable goal, and that progress will also be
included in the annual progress report. According to the Strategy, the
Federal Leadership Committee plans to issue the first annual progress
report in early 2012. The committee has not developed a template for
the annual progress report, however, and federal officials were unable
to tell us what performance data will be collected and reported in it
to gauge progress. Performance information provided by the agencies in
the first quarterly report on progress made during the first quarter
of fiscal year 2011 varies. In some cases the report has no
description of progress made on some actions, general information
about steps taken toward some actions, and detailed information about
progress made in others.
It Is Unclear What Indicators Will Be Used to Assess Bay Health:
There are now two groups--the Federal Leadership Committee and the Bay
Program--that plan to assess bay health. According to the Strategy,
the committee's annual progress report will review indicators of
environmental conditions in the bay, in addition to progress made in
implementing the Strategy. In addition, since 2004, the Bay Program
has assessed bay restoration progress through annual assessments of
the health and restoration of the bay and its watershed, called the
Bay Barometer.[Footnote 22] Both the Federal Leadership Committee and
the Bay Program plan to assess bay health in 2011 and publish these
assessments in 2012. However, federal officials told us that they have
not yet determined the content of next year's Bay Barometer report. It
is therefore unclear if the Federal Leadership Committee and Bay
Program will assess the same or different indicators of progress
toward bay health.
Even though two different assessments of bay health in 2012 could
present a consistent message of bay health, they could also result in
confusion. For example, assessments based on different indicators
could draw different, and possibly contradictory, conclusions about
progress made in improving the overall health of the bay. The team
created in June 2010 to align Strategy and Bay Program goals reported
in January 2011 that the restoration effort is facing difficulty
tracking progress and communicating that progress. The Strategy calls
for the Federal Leadership Committee to coordinate with the watershed
states to align the annual progress report with the Bay Barometer,
but, according to EPA officials, the status of this alignment is
unclear.
Conclusions:
Efforts to restore the Chesapeake Bay have been ongoing for several
decades. The restoration effort has seen some successes in certain
areas, but the overall health of the bay remains degraded. Restoring
the bay is a massive, complex, and difficult undertaking that requires
the concerted effort of many parties. Numerous federal and state
agencies and others all play a role in the effort. To restore the bay
in the most efficient and effective manner, these parties must work
together toward the same goals. The Strategy that federal agencies
developed for protecting and restoring the bay in response to
Executive Order 13508 identifies measurable bay restoration goals and
actions to achieve these goals. State participation in the Strategy is
necessary to achieve these goals, yet the watershed states are not
committed to the Strategy. Currently, federal agencies are generally
working toward the Strategy goals, while states are largely focused on
accomplishing tasks associated with the bay TMDL, which supports one
of the Strategy goals. Having common goals, among other factors, can
help lead to increased participation and cooperation among groups
involved in a collaborative effort and improve natural resource
conditions.
The Federal Leadership Committee and the Chesapeake Bay Program have
recognized the need to align federal and state efforts to restore the
bay. But regardless of how efforts are aligned, if the agencies do not
identify milestones for accomplishing the entire restoration effort,
they may not be able to show when particular actions are expected to
result in progress toward measurable goals. Furthermore, the agencies
have not yet developed an adaptive management process, which is
essential to evaluating whether actions are leading to goals and make
adjustments as necessary. In addition, the Strategy calls for the
Federal Leadership Committee to coordinate with the watershed states
to align Strategy and Bay Program assessments. However, the status of
this alignment is unclear, and both the committee and Bay Program plan
to assess bay health. If they use different indicators to assess and
report, confusion could result about the overall message of progress
made in improving the health of the bay, because assessments based on
different indicators could draw different, and possibly contradictory,
conclusions about the overall health of the bay.
Recommendations for Executive Action:
To improve the likelihood that bay restoration is attained, we
recommend that the Administrator of EPA work collaboratively with
federal and state bay restoration stakeholders to take the following
four actions:
* develop common bay restoration goals to help ensure that federal and
state restoration stakeholders are working toward the same goals,
* establish milestones for gauging progress toward measurable goals
for the entire restoration effort,
* develop an adaptive management process that will allow restoration
stakeholders to evaluate progress made in restoring the bay and adjust
actions as needed, and:
* identify the indicators that will be used for assessing progress
made in improving bay health and clarify how the entities responsible
for assessing this progress will coordinate their efforts.
Agency Comments, Third-Party Views, and our Evaluation:
We provided EPA and the Departments of Agriculture, Commerce, Defense,
Homeland Security, the Interior, and Transportation with a draft of
this report for their review and comment. We also provided the
District of Columbia, Delaware, Maryland, New York, Pennsylvania,
Virginia, West Virginia, and the Chesapeake Bay Commission with a
draft of this report for their review and comment. EPA provided
written comments and generally agreed with our recommendations. EPA
also provided technical comments, which we incorporated as
appropriate. Its written comments are reproduced in appendix V. The
Department of Homeland Security provided written comments but did not
comment on our recommendations. Its written comments are reproduced in
appendix VI. The Department of the Interior disagreed with some of our
findings and recommendations. Its written comments are reproduced in
appendix VII. New York provided written comments but did not comment
on our recommendations. New York also provided technical comments,
which we incorporated as appropriate. Its written comments are
reproduced in appendix VIII. The Departments of Agriculture and
Transportation, the District of Columbia, and Virginia provided
technical comments, which we incorporated as appropriate. The
Departments of Commerce and Defense, Delaware, Maryland, Pennsylvania,
West Virginia, and the Chesapeake Bay Commission had no comments.
EPA generally agreed with our four recommendations. In commenting on
our recommendation that the Administrator of EPA work collaboratively
with federal and state bay restoration stakeholders to develop common
bay restoration goals, EPA noted that there is a new complexity
regarding restoration goals given the development of the Strategy and
that the completion dates for most Chesapeake 2000 Agreement
commitments are set for 2010 or before. We agree. As we noted in the
draft report, restoring the bay is a massive, complex, and difficult
undertaking that requires the concerted effort of many parties. To
restore the bay in the most efficient and effective manner, these
parties must work together toward the same goals. Having common goals,
among other factors, can help lead to increased participation and
cooperation among the groups involved in the effort. In its comments,
EPA stated that the draft report did not highlight where common goals
and common directions are already present in the Chesapeake Bay
Program. We noted in the draft report that the bay TMDL was
incorporated into the Strategy's water quality broad goal, which means
that the pollution reduction steps that the states plan to implement
to achieve the TMDL should contribute to the accomplishment of the
Strategy goal. In commenting on our recommendation that the
Administrator of EPA work collaboratively with federal and state bay
restoration stakeholders to establish milestones for gauging progress
toward measurable goals for the entire restoration effort, EPA
recognized that a blueprint of milestones through 2025 would be
useful. EPA expressed concern about locking in a too detailed plan for
the entire time period, because it does not wish to limit its ability
for adaptive management. We believe that a blueprint of milestones can
assist in the adaptive management process. As we noted in the draft
report, a blueprint of milestones would allow agencies to show when
the actions are expected to result in progress toward the measurable
goals, determine whether these actions are having their intended
result, and make changes to these actions as needed. We also reported
that establishing milestones for an entire effort can improve the
chances the effort can be accomplished efficiently and on time and
provide decision makers with an indication of the incremental progress
the agency expects to make in achieving results. In commenting on our
recommendation that the Administrator of EPA work collaboratively to
develop an adaptive management process that will allow restoration
stakeholders to evaluate progress made in restoring the bay and adjust
actions as needed, EPA acknowledged that this concern has been raised
in previous GAO reports and in a recent National Academy of Sciences
report. EPA also noted that a seven-step adaptive management decision
framework was adopted by the Bay Program in May 2011 and endorsed by
the Bay Program's leadership in July 2011. However, as we note in the
report, this framework was developed for the Bay Program and does not
include clear linkages to the Strategy actions and measurable goals.
It is unclear how this framework will be used by the Federal
Leadership Committee agencies to adaptively manage Strategy actions
and meet Strategy goals. It is presented in appendix IV. In commenting
on our recommendation that the Administrator of EPA should work
collaboratively to identify the indicators that will be used for
assessing progress made in improving bay health and clarify how the
entities responsible for assessing this progress will coordinate their
efforts, EPA noted that it is now working with its federal and state
partners to identify measures that will be used to assess bay health,
and that this group will make recommendations on which reports will be
used to report measures of progress.
The Department of the Interior stated that it does not agree with some
of our draft report's findings and recommendations. First, Interior
stated that our draft report did not recognize that the Strategy
provides a framework to advance the Bay Program beyond the Chesapeake
2000 Agreement. As we noted in our draft report, the Chesapeake Bay
Program is a partnership at the federal, state, and local levels. The
Strategy provides specific outcomes to be achieved by the federal
agencies, but the watershed states have not committed to the Strategy,
and most watershed state officials told us that their bay restoration
work is conducted according to their commitments to the Chesapeake
2000 Agreement. The report also noted that an alignment action team
was formed in June 2010 to work toward aligning Strategy restoration
efforts with those of the Bay Program. Second, Interior commented that
our report understated the level of collaboration and coordination
with the States. We noted in the draft report that federal agencies
and watershed states are working on bay issues through the Goal
Implementation Teams and that, according to EPA officials, these teams
will be used to refine priorities and areas of programmatic focus for
the restoration effort. Finally, Interior stated that it believes some
of the draft report's findings are based on insufficient information.
We have provided detailed responses to this and other Interior
comments in appendix VII.
We are sending copies of this report to the appropriate congressional
committees, the Administrator of EPA, and other interested parties. In
addition, the report will be available at no charge on the GAO website
at [hyperlink, http://www.gao.gov].
If you or your staff members have any questions about this report,
please contact me at (202) 512-3841 or trimbled@gao.gov. Contact
points for our Offices of Congressional Relations and Public Affairs
may be found on the last page of this report. GAO staff who made major
contributions to this report are listed in appendix IX.
Signed by:
David C. Trimble:
Director:
Natural Resources and Environment:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
This appendix provides information on the scope of work and the
methodology used to determine (1) the extent to which the Strategy for
Protecting and Restoring the Chesapeake Bay Watershed (the Strategy)
includes measurable goals for restoring the Chesapeake Bay that are
shared by stakeholders and actions to attain these goals;[Footnote 23]
(2) the key factors, if any, federal and state officials identified
that may reduce the likelihood of achieving Strategy goals and
actions; and (3) agency plans for assessing progress made in
implementing the Strategy and restoring bay health.
To determine the extent to which the Strategy includes measurable
goals for restoring the Chesapeake Bay that are shared by stakeholders
and actions to attain these goals, we reviewed the Strategy to
understand its structure and identify goals and actions. For the
actions, we focused on the 116 actions that are designed to lead
directly to the Strategy's goals. We did not evaluate an additional 51
actions in the Strategy that were designed to provide cross-cutting
support for attaining the goals. We also reviewed previous bay
restoration agreements, such as Chesapeake 2000, to identify previous
bay restoration goals. In addition, we interviewed officials from each
of the federal entities involved in developing and overseeing the
implementation of the Strategy, which make up the Federal Leadership
Committee: the Departments of Agriculture, Commerce, Defense, Homeland
Security, the Interior, and Transportation, and the Environmental
Protection Agency (EPA). We also interviewed officials from each of
the states in the watershed--Delaware, Maryland, New York,
Pennsylvania, Virginia, and West Virginia--and the District of
Columbia, collectively referred to as watershed states in this report,
and representatives of other Chesapeake Bay organizations, such as the
Chesapeake Bay Foundation, to gain an understanding of the Strategy
and bay restoration efforts in general.
To determine the key factors federal and state officials identified
that may reduce the likelihood of achieving Strategy goals and
actions, we first surveyed officials from each of the 11 agencies
responsible for creating and implementing the Strategy and received
responses from January 2011 through May 2011. These agencies are EPA;
the Department of Agriculture's Forest Service and Natural Resources
Conservation Service; the Department of Commerce's National Oceanic
and Atmospheric Administration; the Department of Defense's Navy and
U.S. Army Corps of Engineers; the Department of Homeland Security; the
Department of the Interior's National Park Service, Fish and Wildlife
Service, and U.S. Geological Survey; and the Department of
Transportation. For each agency, we identified as respondents federal
officials who participated in Strategy development and implementation
on behalf of their agencies, through agency interviews. We used the
survey to obtain and analyze information from each of the agencies
about each action and measurable goal for which the agency had
responsibility, and about each of the Strategy's four broad goals. The
questionnaire used for this study is available in appendix II. We sent
the questionnaire by e-mail, and respondents returned it by e-mail
after marking checkboxes or entering responses into open answer boxes.
All of the agencies responded to our survey.
To identify key factors that could reduce the likelihood of achieving
Strategy goals and actions, we conducted a content analysis of
responses to question 2 from both the actions and measurable goals
portions of the survey. Two analysts independently reviewed the
agencies' responses to each question and together identified the
categories most often cited in these responses. They then coded each
survey response into those categories. In cases where differences
between the two reviewers regarding the coding of responses into
content categories were found, all differences were resolved through
reviewer discussion. Ultimately, there was 100 percent agreement
between the reviewers. See appendix III for further analysis we
conducted with survey data.
Because this was not a sample survey, it has no sampling errors. To
ensure the reliability of the data collected through our survey of the
11 Strategy agencies, we took a number of steps to reduce measurement
error, nonresponse error, and respondent bias. These steps included
conducting three pretests in person prior to distributing the survey
to ensure that our questions were clear, precise, and consistently
interpreted; reviewing responses to identify obvious errors or
inconsistencies; and conducting follow-up interviews with officials to
review and clarify responses. We determined the survey data to be
sufficiently reliable for the purposes of this report.
In addition to conducting the survey mentioned above, we interviewed
officials from each of the watershed states to determine their
knowledge of and involvement with the Strategy; to identify the
factors, if any, that state officials believe could reduce the
likelihood of both Strategy and bay restoration success; and to ask
about state-related federal official survey responses. We also
interviewed a nonprobability sample of individuals who have expertise
in the subject matter of the Strategy's measurable goals and solicited
their views on the likelihood that the measurable goals could be
achieved. We identified these individuals primarily through GAO's
prior work on the Chesapeake Bay, and the final list included mostly
faculty and staff from the University of Maryland's Center for
Environmental Science and the Virginia Institute of Marine Studies. We
asked them questions to determine the nature and extent of their
expertise, and to ensure that they were not currently or recently
employed by EPA and that they had not contributed to the Strategy. We
developed a semistructured interview guide containing open-ended
questions to solicit responses about their familiarity with the
Strategy and the measurable goals that correlated with their area of
expertise. We interviewed nearly all of the experts by telephone.
Because we used a nonprobability sample, the information obtained from
these interviews is not generalizable to other members of academia
with bay-related expertise.
To determine the plans in place for assessing the progress of
implementing the Strategy and restoring the bay, we reviewed the
Strategy and related assessment documents, such as an action plan and
a quarterly progress report. We also reviewed several Bay Barometers,
annual bay restoration assessment documents issued by the Chesapeake
Bay Program.[Footnote 24] In addition, we interviewed EPA officials
who represent the Federal Leadership Committee and the Chesapeake Bay
Program Office--the office that represents the federal government with
the Chesapeake Bay Program--to discuss how they plan to assess
progress on implementing the Strategy and restoring bay health, and
also to identify any additional methods EPA plans to use to assess
progress in these areas. We also spoke with officials from each of the
other Strategy agencies about their roles in assessing Strategy
progress.
We conducted this performance audit from August 2010 to September 2011
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.
[End of section]
Appendix II: Survey Questions:
[End of section]
We surveyed officials from each of the federal agencies involved with
creating and overseeing the implementation of the Strategy using all
of the questions below as stated here. We provided these questions to
the officials in a format that identified the Strategy actions,
measurable goals, and broad goals for which their agency had
responsibility as identified in the Federal Leadership Committee's
Fiscal Year 2011 Action Plan.[Footnote 25]
[End of section]
In our survey, we asked officials from each Strategy agency the
following questions regarding each action for which the agency has
responsibility:
1. Do you believe this action can be accomplished by the action
deadline, assuming current and expected budget and staff levels? (If
no deadline is specified, please use the overall Strategy deadline of
2025 as the default deadline.)
* Definitely yes:
* Probably yes:
* Probably no:
* Definitely no:
* Don't know:
* My agency is not responsible for this action.
1a. Please explain your answer. (For example, please describe whether
certain portions of this action are more or less likely to be
accomplished by the deadline than others.
2. What factors do you foresee, if any, that could reduce the
likelihood this action will be accomplished? (Please list and briefly
describe the factors. This could include factors within or beyond your
agency's control.)
3. Is participation from agencies of any of the following state
governments necessary for your agency to accomplish this action?
(Please check all that apply. Please consider the entire duration of
time during which your agency will be working on this action.)
* Delaware:
* District of Columbia:
* Maryland:
* New York:
* Pennsylvania:
* Virginia:
* West Virginia:
* Other (please list in 3a):
* None:
* Don't know.
3a. If you checked "Other" in 3, please list the state government(s)
necessary for your agency to accomplish this action.
4. If this action were not completed, how would this affect the
likelihood of achieving the outcome or goal listed below the drop down
box?
* Achieving the outcome or goal would be far less likely:
* Achieving the outcome or goal would be somewhat less likely:
* Achieving the outcome or goal would be no less likely:
* Don't know.
4a. Please explain your answer to 4.
We asked officials from each agency the following questions regarding
each measurable goal (which are referred to as outcomes in the
Strategy and in our survey questions) that contain an action for which
the agency has responsibility. For actions in the water quality broad
goal that are listed under more than one measurable goal, we asked the
relevant agencies question 4 twice, once for each measurable goal.
1. If all the actions for this outcome (including those for which your
agency or other agencies are responsible) are completed, do you
believe the outcome will be achieved?
* Definitely yes:
* Probably yes:
* Probably no:
* Definitely no:
* Don't know.
1a. Please explain your answer. (For example, please describe whether
certain portions of this outcome are more or less likely to be
achieved by the deadline than others.)
2. If all the actions for this outcome (including those of your agency
and other agencies) are completed, what factors do you foresee, if
any, that could reduce the likelihood that this outcome will be
achieved? (Please list and briefly describe the factors. This could
include factors within or beyond your agency's control.)
3. How important is this outcome to attaining the goal listed below
the drop down box?
* Very important:
* Somewhat important:
* Not at all important:
* Don't know.
We asked officials from each agency the following questions regarding
each broad goal (which are referred to as goals in the Strategy and in
the survey) that contain an action for which the agency has
responsibility.
1. If all of the outcomes for this goal are achieved, do you believe
the goal will be attained?
* Definitely yes:
* Probably yes:
* Probably no:
* Definitely no:
* Don't know.
1a. Please explain your answer.
2. How important is achieving this goal to restoring the overall
health of the bay?
* Very important:
* Somewhat important:
* Not at all important:
* Don't know.
We asked officials from each agency the following general questions.
1. Please provide any additional comments you may have about the
Strategy or your responses in this data collection instrument.
2. Please list any actions for which your agency is responsible that
we did not ask about.
[End of section]
Appendix III: Collaboration Needed between Federal Agencies and
Watershed States to Accomplish Strategy Actions:
Collaboration between federal agencies and the watershed states will
be required to complete many of the Strategy actions. In response to
question 3 of the actions portion of our survey, federal officials
identified Strategy actions that require state participation in order
to accomplish the actions. In those cases where federal officials
reported that state participation was necessary to accomplish the
action, the officials identified the necessary state or states. Figure
3 shows the extent of collaboration that will be needed between
federal agencies and watershed states to accomplish Strategy actions.
Each node represents a federal agency or a state. Each link between a
pair of nodes indicates that the corresponding entities will need to
collaborate to accomplish an action. Thicker links indicate more
extensive collaboration because of the number of times federal
officials identified participation from a particular state as
necessary. Table 3 shows the number of actions for which each federal
agency reported that participation from a watershed state was
necessary to accomplish the action.
Figure 5: Extent of Collaboration Needed between Federal Agencies and
Watershed States to Accomplish Strategy Actions:
[Refer to PDF for image: illustration]
Number of actions that require collaboration between a federal agency
and a watershed state:
More than 16: actions:
EPA and Maryland;
EPA and Virginia;
EPA and Pennsylvania;
EPA and Delaware;
EPA and New York;
EPA and West Virginia;
EPA and District of Columbia;
Fish and Wildlife Service and Maryland;
Fish and Wildlife Service and Virginia;
Fish and Wildlife Service and Pennsylvania;
Fish and Wildlife Service and Delaware;
Fish and Wildlife Service and New York;
Fish and Wildlife Service and West Virginia;
U.S. Geological Survey and Maryland;
National Oceanic and Atmospheric Administration and Maryland;
National Oceanic and Atmospheric Administration and Virginia.
6-15 actions:
Fish and Wildlife Service and District of Columbia;
U.S. Geological Survey and Virginia;
U.S. Geological Survey and Pennsylvania;
U.S. Geological Survey and Delaware;
U.S. Geological Survey and New York;
U.S. Geological Survey and West Virginia;
U.S. Geological Survey and District of Columbia;
National Park Service and Maryland;
National Park Service and Virginia;
National Park Service and Pennsylvania;
National Park Service and Delaware;
National Park Service and New York;
National Park Service and West Virginia;
National Park Service and District of Columbia;
National Oceanic and Atmospheric Administration and District of
Columbia;
Natural Resources Conservation Service and Maryland;
Natural Resources Conservation Service and Virginia;
Natural Resources Conservation Service and Pennsylvania;
Natural Resources Conservation Service and Delaware;
Natural Resources Conservation Service and New York;
Natural Resources Conservation Service and West Virginia;
Forest Service and Maryland;
U.S. Army Corps of Engineers and Maryland;
U.S. Army Corps of Engineers and Virginia.
1-5 actions:
National Oceanic and Atmospheric Administration and Pennsylvania;
National Oceanic and Atmospheric Administration and Delaware;
National Oceanic and Atmospheric Administration and New York;
National Oceanic and Atmospheric Administration and West Virginia;
Forest Service and Virginia;
Forest Service and Pennsylvania;
Forest Service and Delaware;
Forest Service and New York;
Forest Service and West Virginia;
Forest Service and District of Columbia;
Department of Transportation and Maryland;
Department of Transportation and Virginia;
Department of Transportation and Pennsylvania;
Department of Transportation and Delaware;
Department of Transportation and New York;
Department of Transportation and West Virginia;
Department of Transportation and District of Columbia;
Navy: No actions.
Source: GAO analysis of survey responses.
[End of figure]
Table 3: Number of Actions for Which Each Federal Agency Reported That
Participation from a Watershed State Was Necessary to Accomplish the
Action:
Federal agency: Environmental Protection Agency;
Maryland: 20;
Virginia: 19;
Pennsylvania: 19;
New York: 19;
Delaware: 19;
West Virginia: 19;
District of Columbia: 20.
Federal agency: Fish and Wildlife Service;
Maryland: 24;
Virginia: 24;
Pennsylvania: 19;
New York: 18;
Delaware: 19;
West Virginia: 18;
District of Columbia: 6.
Federal agency: U.S. Geological Survey;
Maryland: 19;
Virginia: 14;
Pennsylvania: 14;
New York: 9;
Delaware: 11;
West Virginia: 10;
District of Columbia: 9.
Federal agency: National Park Service;
Maryland: 12;
Virginia: 12;
Pennsylvania: 11;
New York: 10;
Delaware: 11;
West Virginia: 10;
District of Columbia: 12.
Federal agency: National Oceanic and Atmospheric Administration;
Maryland: 22;
Virginia: 22;
Pennsylvania: 3;
New York: 3;
Delaware: 3;
West Virginia: 1;
District of Columbia: 8.
Federal agency: Natural Resources Conservation Service;
Maryland: 9;
Virginia: 9;
Pennsylvania: 9;
New York: 8;
Delaware: 8;
West Virginia: 8;
District of Columbia: 0.
Federal agency: Forest Service;
Maryland: 6;
Virginia: 5;
Pennsylvania: 5;
New York: 5;
Delaware: 5;
West Virginia: 5;
District of Columbia: 1.
Federal agency: U.S. Army Corps of Engineers;
Maryland: 12;
Virginia: 8;
Pennsylvania: 4;
New York: 2;
Delaware: 1;
West Virginia: 1;
District of Columbia: 1.
Federal agency: Department of Transportation;
Maryland: 4;
Virginia: 4;
Pennsylvania: 4;
New York: 4;
Delaware: 4;
West Virginia: 4;
District of Columbia: 4.
Federal agency: Navy;
Maryland: 0;
Virginia: 0;
Pennsylvania: 0;
New York: 0;
Delaware: 0;
West Virginia: 0;
District of Columbia: 0.
Source: GAO analysis of survey responses.
[End of table]
[End of section]
Appendix IV: Chesapeake Bay Program Adaptive Management Decision
Framework:
The Chesapeake Bay program approved the following adaptive management
decision framework on May 10, 2011, as an incremental step in moving
toward adaptive management:
1. Articulate program goals. Identify the goals the goal
implementation team is working toward.
2. Describe factors influencing goal attainment. Identify and
prioritize all factors that influence performance toward a goal. This
step can help identify areas for cross-goal implementation team
collaboration.
3. Assess current management efforts (and gaps). Identification of
gaps/overlaps in existing management programs addressing the important
factors affecting goal attainment.
4. Develop management strategy. Coordination and implementation
planning by stakeholders.
5. Develop monitoring program.
6. Assess performance. Criteria for success/failure of management
efforts should be known when the strategy is developed and the
monitoring program is designed. This is the analysis that informs
program adaptation. This helps inform next steps.
7. Manage adaptively. Based on the monitoring assessment, system
models are amended, and monitoring strategies are revised to improve
program performance.
[End of section]
Appendix V: Comments from the Environmental Protection Agency:
United States Environmental Protection Agency:
Washington, DC 20460:
September 7, 2011:
Mr. David C. Trimble:
Director:
Natural Resources and Environment:
U.S. Government Accountability Office:
Washington, D.C. 20548:
Dear Mr. Trimble:
Thank you for the opportunity to review and comment on the draft
report Chesapeake Bay: Restoration Effort Needs Common Federal and
Stale Goals and Assessment Approach, which examines recent
developments in the Chesapeake Bay Program and offers four
recommendations. the U.S. Environmental Protection Agency is in
general agreement with all four recommendations, and we are pleased to
share some thoughts in this letter and more detailed comments in an
attached document.
First recommendation: The Chesapeake Bay Program should develop common
bay restoration goals to help ensure that federal and state
restoration stakeholders are working toward the same goals.
The EPA's Response: As the report notes, with the completion dates for
most of the commitments in the Chesapeake 2000 Agreement set for 2010
or before and with the direction from President Barack Obama to
develop a strategy for implementing Executive Order 13508 Chesapeake
Bay Protection and Restoration. there is a new complexity regarding
programmatic goals. The draft report highlights instances of this
complexity, but does not highlight instances where common goals and
common directions are already present in the Chesapeake Bay Program.
For instance, improving water quality, a goal that includes measurable
parameters, is supported by the Bay watershed jurisdictions and is
being implemented through the Chesapeake Bay total maximum daily load
and the jurisdictions' watershed implementation plans. The states
might have been unable to commit to the specific metric and time frame
associated with many of the outcomes at this point. However, they did
agree to work with the federal agencies through a process agreed to by
the Chesapeake Executive Council and the Federal Leadership Committee
for the Chesapeake Bay that will immediately begin to set goals and
areas of programmatic and geographic focus through the Chesapeake
Bay Program's goal implementation teams and will be guided by key
strategies and agreements, such as Chesapeake 2000, Executive Council
directives and the Executive Order strategy.
If the leadership deems a new agreement is necessary to ensure
commitment to these goals and priorities, they have further committed
to develop a new agreement no later than the 2013 Executive
Council meeting. For details on the full agreement on aligning the
Executive Order goals with the Chesapeake Bay Program Partnership,
please see the attached Coordinating Chesapeake Bay Program and
Federal Leadership Committee Goals. Outcomes and Actions.
Second recommendation: The Chesapeake Bay Program should establish
milestones for gauging progress toward measurable goals for the entire
restoration effort.
The EPA's Response: As discussed in the draft report, the bay
watershed jurisdictions have developed two-year milestones, and the
federal agency partners are developing two-year milestones that will
cover 2012 and 2013. The EPA believes that the goals established in
the Executive Order strategy provide important targets to be achieved
by meeting the two-year milestones. Agencies and other stakeholders
will be able to measure progress toward those targets to determine
whether adequate progress is being made.
Finally, the EPA believes that while a blueprint of milestones through
2025 would be useful, such a document would do little to ensure that
each milestone would he Islet, particularly given the current climate
of budgetary uncertainty. While we agree that a general blueprint that
highlights the approach used for meeting restoration goals through
2025 is important - assuming that there will be a slower start that
will accelerate later, that there will be steady rate of
implementation over time or that there will be faster implementation
at first and slowing later - we do not wish to limit our ability for
adaptive management by locking in a too-detailed plan for the entire
time period.
Third recommendation: The Chesapeake Bay Program should develop an
adaptive management program that will allow restoration stakeholders
to evaluate progress made in restoring the hay and adjust actions as
needed.
The EPA's Response: The EPA acknowledges that this concern has been
raised in previous GAO reports and in the recent National Academy of
Science's report on the program. The EPA and its program partners are
continuing to more clearly articulate and institutionalize an adaptive
management process throughout the program. In May 2011, the Chesapeake
Bay Program's principals' staff committee adopted a decision-support
framework that enables effective adaptive management in the
Chesapeake Bay Program. It was later endorsed by the Chesapeake Bay
Program's leadership at the July 2011 Executive Council Meeting. The
framework is a seven-step process that articulates program goals,
describes factors influencing goal attainment, assesses current
management efforts and gaps, develops a management strategy, develops
a monitoring program, assesses performance and manages adaptively.
An important step in the implementation of this approach is the
development of ChesapeakeStat, a Web-based decision-support tool that
provides a wealth of environmental, financial and other information
for all aspects of the Chesapeake Bay Program. To pilot this approach
prior to the July 2011 Executive Council meeting, two goal
implementation teams used ChesapeakeStat to collect, analyze and enter
information on particular goals - reducing pollution related to
agricultural practices and restoring underwater grasses - into the
decision framework so they can begin to use adaptive management to
support decision making. The Executive Council agreed that the
Chesapeake Bay Program would use this framework when aligning the
Executive Order strategy goals with the program. This is an area in
which the program will continue to improve.
Fourth recommendation: The Chesapeake Bay Program should identify the
indicators that will be used for assessing progress made in improving
hay health and clarify how the entities responsible for assessing this
progress will coordinate their efforts.
The EPA's Response: The Chesapeake Bay Program is always exploring
better and more complete ways to use information and indicators to
report on the health of the Chesapeake Bay, its rivers and the
watershed. New indicators for outcomes not currently described in
Chesapeake 2000 will be used as part of the adaptive management
process described above. Through the Chesapeake Bay Program, the EPA
and its federal and state partners arc now working on identifying
measures that will be used to assess the health of the bay, the rivers
and the watershed and identifying measures of progress being made by
federal and state partners to improve bay health. The group will also
make recommendations on which reports, such as Bay Barometer and the
Executive Order Progress Report, will be used to report measures of
progress. The EPA is advocating for inclusion of all of these measures
in ChesapeakeStat so that any interested party will he able to review
our progress in a transparent and timely manner.
Finally, we appreciate the thoughtful work of the Government
Accountability Office's staff members during this review and their
constructive engagement with Chesapeake Bay Program Office staff
members and representatives of our partner agencies and jurisdictions.
Sincerely,
Signed by:
Bob Perciasepe:
Attachments:
[End of section]
Appendix VI: Comments from the Department of Homeland Security:
Department of Homeland Security:
Washington, DC 20528:
September 1, 2011:
David C. Trimble:
Director. Natural Resources and Environment:
441 G Street, NW:
U.S. Government Accountability Office:
Washington DC 20548:
Re: Draft Report GAO-11-802, "Chesapeake Bay: Restoration Effort Needs
Common Federal and State Goals and Assessment Approach"
Dear Mr. Trimble:
Thank you for the opportunity to review and comment on this draft
report. The U.S. Department of Homeland Security (DHS) appreciates the
U.S. Government Accountability Office's (GAO's) work in planning and
conducting its review and issuing this report.
The Department is pleased to note CiA0-s positive acknowledgment of
many Federal leadership Committee efforts related to restoring and
protecting the Chesapeake Bay. Although the report does not contain
any recommendations directed at DHS the Department remains committed
to continuing its collaboration with partners, such as the
Environmental Protection Agency, and the U.S. Departments of
Agriculture, Commerce, and Interior, among others to improve the
health of the bay.
Again, thank you for the opportunity to review and comment on this
draft report. We look forward to working with you on future homeland
security issues.
Sincerely,
Signed by:
Jim H. Crumpacker:
Director:
Departmental GAO-OIG Liaison Office:
[End of section]
Appendix VII: Comments from the Department of the Interior:
Note: GAO comments supplementing those in the report text appear at
the end of this appendix.
United States Department of the Interior:
Office Of The Secretary:
Washington, DC 20240:
August 31, 2011:
Mr. David Trimble:
Director, Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street, N.W.
Washington, D.C. 20548:
Dear Mr. Trimble:
The Department of the Interior (DOI) has reviewed the draft Government
Accountability Office (GAO) report titled Chesapeake Bay: Restoration
Effort Needs Common Federal and State Goals and Assessment Approach
(GA0-11-802). The DOI does not agree with some of the findings and
recommendations in the draft report. Our primary concerns include:
* The GAO draft report does not recognize that the May 2010 Strategy
for Protecting and Restoring the Chesapeake Bay provides a framework
to advance the Chesapeake Bay Program beyond the outdated and expired
commitments in the Chesapeake 2000 agreement.
* GAO understates the level of collaboration and coordination with the
States.
* We believe that some of the draft report's findings are based on
insufficient information.
Enclosed are detailed comments on the findings and recommendations.
We hope these comments will assist you in preparing the final report.
If you have any questions, or need additional information, please
contact David Russ at (703) 648-6660, Scott Phillips at (443) 498-
5552, John Maounis at (410) 260-2471 or Mike Slattery at (410) 260-
2487.
Sincerely,
Signed by:
Pamela Haze, Acting for:
Rhea Suh:
Assistant Secretary:
Policy, Management and Budget:
Enclosure:
[End of letter]
Enclosure:
Department of the Interior Comments in Response to the GAO Draft Report
Chesapeake Bay: Restoration Effort Needs Common Federal and State
Goals and Assessment Approach:
Specific comments on GAO findings:
GAO Finding: Restoration Strategy Includes Measurable Goals and Action
to Achieve Them, but Not All Bay Restoration Stakeholders are Working
Toward These Goals (p. 10-15).
Comments: The May 2010 Strategy for Protecting and Restoring the
Chesapeake Bay Watershed (Strategy) offers the next generation of
specific outcomes to be achieved by the Chesapeake Bay Program (CBP).
Most of the specific outcomes in the Chesapeake 2000 agreement have
expired. The Strategy outcomes were developed, as directed in the
President's Chesapeake Bay Executive Order, to move the program
forward. Federal partners, in consultation with States, worked to
develop new outcomes to guide the program for the future (2025),
building upon the general goals of the existing Chesapeake 2000
agreement. The Strategy adds measurable watershed outcomes, which were
developed with the States. Modifications were made, based on State
comments. However, the States chose not to formally adopt the new
outcomes. One reason for States' not adopting the new outcomes was
that their primary focus was on meeting their regulatory requirements
under the Total Maximum Daily Load (TMDL) process. The States'
Watershed Implementation Plans for the TMDL were also due in 2010. We
agree that common, measurable goals are ideal, but we are not in a
position to force State participation. The CBP Principal Staff
Committee (PSC) directed the five Goal Teams to align the commitments
in the Chesapeake 2000 agreement with the Strategy outcomes. This will
result in a shared set of goals for all partners by 2013.
GAO Finding: Federal and State Officials Identified Three Key Factors
that May Reduce the Likelihood of Achieving Strategy Goals and Actions
(p. 16-19). [See comment 1]
Comments: Federal agencies have made progress on the three areas
identified by GAO-—collaboration, funding constraints, and external
phenomena.
Federal and State partners consulted through the Bay Program Committee
structure on the Strategy and associated goals. This structure
includes the PSC, the Management Board, the Goal Implementation Teams,
and the Advisory Committees. The Strategy was discussed at three PSC
meetings during 2009 and 2010, and at another two-day meeting in
February 2010. The PSC consists of representatives from eight Federal
agencies and 19 State agencies from all major jurisdictions in the
watershed (six States and the District of Columbia), and the
Chesapeake Bay Commission. The Strategy was also discussed at the
meetings of the five Goal Implementation Teams and the three Advisory
Committees (Citizens, Local Governments, and Science) between 2009 and
2010. [See comment 2]
Since the Strategy was released in May 2010, Federal and State
collaboration has continued through the PSC, with more direct
collaboration on Strategy outcomes within the five CBP Goal Teams and
the Science Support Team. State and Federal partners share leadership
of the five Goal Teams, which meet at least every other month. Each
Goal Team is focusing on specific Federal and State actions to meet
the Chesapeake 2000 goals and to address the new Strategy outcomes.
Funding constraints are a legitimate concern. The President's
requested budgets in both 2011 and 2012 would have adequately
supported the actions in the Strategy. However, Congress did not
appropriate funds at the requested level in 2011. Appropriations for
2012 are pending Congressional action. Based on initial House action,
there is a high probability of reduced budgets. As a result, some
actions cannot move forward. The Federal agencies have prioritized
actions to maximize progress toward achieving the Strategy goals.
Constraints on State budgets will also slow progress on CBP goals.
As a result, some actions cannot move forward. The Federal agencies
have prioritized actions to maximize progress toward achieving the
Strategy goals. Constraints on State budgets will also slow progress
on CBP goals.
We agree with the GAO finding that external phenomena, including
climate change, could have an effect on achieving the Strategy's
goals. However, the GAO did not review or take into account the
Strategy chapter describing how the Federal agencies propose to adapt
to climate change. These proposals include conducting vulnerability
assessments and monitoring. The resulting information will help State
and Federal partners adapt to climate change. The CBP is addressing
climate change through the Scientific and Technical Advisory Committee
(STAC), which is comprised of Federal agencies and academic
institutions. The STAC meets quarterly. In addition, a STAC workshop
held in March 2011 brought together Federal, State, and academic
partners to develop actions to address climate change. [See comment 3]
GAO Finding: Agency Plans for Assessing Progress on Implementing the
Strategy and Restoring Bay Health are Limited or Not Fully Developed,
and it is Unclear What Indicators Will be Used to Assess Progress on
Bay Health (p. 20-24).
Specific GAO Finding: Milestone Development Plan is Limited.
Comments: We disagree with the GAO's recommendation for a blueprint of
milestones for the entire restoration effort (2011-2025). The 12
outcomes provide the blueprint for the long-term success of the
program. The two-year milestones provide an adaptive management
approach to implement plans, assess progress, and make adjustments as
more is learned (see next comment). [See comment 4]
Specific GAO Finding Plans for Adaptive Management and Annual Progress
Report are Not Fully Developed.
Comments: The GAO did not include information on the CBP's Decision
Framework, which was adopted by State and Federal partners in May
2011. The Decision Framework is a six-step adaptive management process
focused on defining goals, implementing actions, monitoring progress,
and making adjustments. The new adaptive management process was based
on several documents, including information in the "Strengthening
Science" chapter of the Strategy. [See comment 5]
The 2011 Strategy progress report is on schedule to be completed by
January 2012. An outline for the progress report was approved by CEQ
and OMB on August 12, 2011. The performance data for the progress
report is the quarterly information reported by the Federal agencies.
GAO's concern about the performance information (page 22 of the GAO
draft) relates primarily to the Federal agencies' uncertainty under
the continuing resolution. The performance information was refined
when Congress passed a final 2011 appropriation. [See comment 6]
Specific GAO Finding: It is unclear what indicators will be used to
assess Bay health.
Comments: Federal and State partners will continue to work to improve
the CBP publication, Bay Barometer, which reports on the overall
health of the Bay. New indicators for outcomes not previously used in
Chesapeake 2000 will be added, as necessary, as part of the adaptive
management process. The CBP has a team in place (not two groups as
suggested by the GAO draft report) to improve the Bay Barometer for
the next reporting cycle. The team will recommend to the CBP partners
(both Federal and State) any changes to the indicators to assess
Bay health.
GAO Comments:
1. Interior commented that the Strategy offers the next generation of
specific outcomes to be achieved by the Chesapeake Bay Program, which
is a partnership at the federal, state, and local levels. As we noted
in our draft report, the Strategy provides specific outcomes to be
achieved by the federal agencies. In addition, we noted that the
watershed states are critical partners in the restoration effort, and
federal officials reported that watershed state action will be
necessary to accomplish 96 of the 116 Strategy actions. However, the
watershed states have not committed to the Strategy, and officials
from most of the states told us that they are generally unaware of
what federal agencies may require from them to implement the Strategy.
In addition, we noted in the draft report that most watershed state
officials told us that their bay restoration work is conducted
according to their commitments to the Chesapeake 2000 Agreement. The
Strategy recognizes the need to integrate the goals of the Chesapeake
Bay Program with those of the Strategy. We noted in our draft report
that the Federal Leadership Committee and the Bay Program created an
alignment action team in June 2010 to work toward aligning Strategy
restoration efforts with those of the Bay Program, including
Chesapeake 2000 Agreement efforts.
2. Interior commented that we understated the level of collaboration
and coordination with the states, and it provided information on the
Bay Program structure and meetings through which collaboration takes
place. As we reported, most of the federal officials we surveyed
indicated that a potential lack of collaboration among stakeholders
could reduce the likelihood of achieving Strategy goals and actions.
We did not comment in our draft report on the extent to which the
federal agencies and watershed states collaborated in the development
of the Strategy. We noted in the draft report that the federal
agencies and watershed states are working on bay issues through the
Goal Implementation Teams and that, according to EPA officials, bay
restoration stakeholders plan to use these teams to refine priorities
and areas of programmatic focus, guided by the Chesapeake 2000
Agreement and the Strategy.
3. Interior commented that we did not review or take into account the
Strategy chapter describing how the federal agencies propose to adapt
to climate change. In our draft report, we noted that the Strategy
identifies four supporting strategies, including respond to climate
change, and 51 actions associated with these strategies. In addition,
we reported that federal officials told us that effects of external
phenomena, such as climate change, beyond what was planned for in
developing the Strategy could affect the likelihood of achieving the
measurable goals.
4. Interior disagreed with our recommendation to EPA to work with
federal and state bay restoration stakeholders to establish milestones
for gauging progress toward measurable goals for the entire
restoration effort. Interior further commented that the 12 measurable
goals provide a blueprint for the long-term success of the program. As
we noted in the draft report, the 12 measurable goals contain numeric
descriptions of results to be achieved by 2025. However, these
measurable goals do not provide a blueprint of milestones to be met
prior to 2025 that would allow the agencies to determine whether they
are on track to meet these measurable goals. We agree that 2-year
milestones can contribute to an adaptive management approach, and as
we noted in the draft report, a blueprint of milestones for the entire
restoration effort can allow the agencies to show when the actions are
expected to result in progress toward the measurable goals, determine
whether the actions are having their intended results, and make
changes to these actions as needed.
5. Interior commented that we did not include information on the Bay
Program's seven-step adaptive management decision framework. In
response to this comment, we modified the report to include
information about this framework. However, as we note in the report,
this framework was developed for the Bay Program and does not include
clear linkages to the Strategy actions and measurable goals. It is
unclear how it will be used by the Federal Leadership Committee
agencies to adaptively manage Strategy actions and meet Strategy
goals. In August 2011, EPA officials told us that a fully developed
adaptive management process is needed.
6. Interior commented that the annual progress report is on schedule
to be completed by January 2012 and that the Council on Environmental
Quality and Office of Management and Budget approved an outline for
the report on August 12, 2011. According to an EPA official, the
outline that Interior refers to in its comments did not address what
performance information will be collected. We continue to believe that
plans for the annual progress report are not fully developed.
7. Interior commented that a Bay Program team is working to improve
the Bay Barometer publication, which reports on the overall health of
the bay. We noted in our draft report that there are two groups that
plan to assess bay health. The Federal Leadership Committee will
review indicators of environmental conditions in the bay through its
annual progress report, and the Bay Program will report on bay health
and restoration efforts through its Bay Barometer. As we reported, the
content of the next Bay Barometer report has not yet been determined,
and it is unclear if the groups will assess the same or different
indicators of progress.
[End of section]
Appendix VIII: Comments from the State of New York:
New York State Department of Environmental Conservation:
Joe Martens, Commissioner:
Assistant Commissioner:
Office of Water Resources, 14th Floor:
625 Broadway, Albany, New York 12233-1010:
Phone: (518) 402-2794:
Fax: (518) 402-8541:
Website: [hyperlink, http://www.dec.ny.gov]
August 25, 2011:
Mr. David Trimble:
Director, Natural Resources and Environment:
United States Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Director Trimble:
On behalf of the State of New York I am submitting the enclosed
comments on the draft report: "Chesapeake Bay Restoration Effort Needs
Common Federal and State Goals and Assessment Approach". New York
appreciates the opportunity to provide comments and would like to take
this occasion to recognize the efforts of the Environmental Protection
Agency (EPA) to understand the characteristics unique to the New York
portion of the Chesapeake Bay watershed. Without a doubt, the
implementation of Executive Order 13508 and the Chesapeake Bay Total
Maximum Daily Load (TMDL) continues to be a challenging effort for EPA
and the affected states, including New York. A common-sense approach
that ensures that the most cost effective reductions are being put
into place will protect the local economy and keep farmers farming.
It is important to recognize the enormity of the Chesapeake Bay
restoration effort. Funds for locally-led implementation efforts are
being stretched during tough economic times. EPA has recognized the
situation of the States and has come forward with capacity grants for
regulatory agencies and implementation grants for local conservation
efforts. Importantly, in granting these federal funds EPA has been
sensitive to the needs of both the immediate Chesapeake Bay States and
the Headwater States. New York strongly urges Administrator Jackson to
continue her advocacy of funds to address the failing wastewater
infrastructure needs across the country as she did in her testimony
before Congress on the FY 2011 budget. The need for substantially
higher appropriations for the Water Resources Development Act, Clean
Water State Revolving Fund, and United States Department of
Agriculture Rural Development financial support programs has increased
in New York State's portion of the Chesapeake Bay watershed as a
result of the Chesapeake Bay TMDL.
New York recognizes the importance of restoring water quality in the
Chesapeake Bay and appreciates the challenges faced by federal
agencies in implementing Executive Order 13508 and the Chesapeake Bay
TMDL. You can be assured that New York will continue its effective
efforts to protect water resources within its borders, as well as
water quality downstream in the Chesapeake Bay. It is clear that a
continued, and heightened, commitment of federal fiscal resources will
be central to the success of this Presidential initiative. Department
staff, along with key partners at the New York State Department of
Agriculture and Markets and Upper Susquehanna Coalition, look forward
to continuing to work with federal, state and local partners to
marshal the implementation of on-the-ground projects that will succeed
in reducing nutrient and sediment pollution in New York's Susquehanna
and Chemung River Basins.
Thank you for the opportunity to provide comments on the draft report:
"Chesapeake Bay Restoration Effort Needs Common Federal and State
Goals and Assessment Approach." Please direct any questions you may
have concerning these comments to Jacqueline Lendrum at (518) 402-8118
or jmlendru@gw.dec.state.nv.us.
Sincerely,
Signed by:
James M. Tierney:
[End of section]
Appendix IX: GAO Contact and Staff Acknowledgments:
Contact:
David C. Trimble, (202) 512-3841 or trimbled@gao.gov:
Staff Acknowledgments:
In addition to the individual named above, Barbara Patterson,
Assistant Director; Lucas Alvarez; Elizabeth Beardsley; Mark Braza;
Russ Burnett; David Dornisch; Lina Khan; Marietta Mayfield Revesz; Ben
Shouse; Kiki Theodoropoulos; and Michelle K. Treistman made
significant contributions to this report. Elizabeth H. Curda and Kim
S. Frankena also made important contributions to this report.
[End of section]
Footnotes:
[1] Chesapeake Bay Program, Bay Barometer: A Health and Restoration
Assessment of the Chesapeake Bay and Watershed in 2009 (Annapolis, MD:
April 2010).
[2] GAO, Chesapeake Bay Program: Improved Strategies Are Needed to
Better Assess, Report, and Manage Restoration Progress, [hyperlink,
http://www.gao.gov/products/GAO-06-96] (Washington, D.C.: Oct. 28,
2005).
[3] House Appropriations Committee Print, Consolidated Appropriations
Act, 2008, Pub. L. No. 110-161 Div. F at 1256; Consolidated
Appropriations Act, 2008, Pub. L. No. 110-161, § 4 (2007).
[4] GAO, Chesapeake Bay Program: Recent Actions Are Positive Steps
Toward More Effectively Guiding the Restoration Effort, [hyperlink,
http://www.gao.gov/products/GAO-08-1033T] (Washington, D.C.: July 30,
2008).
[5] Executive Order 13508, Chesapeake Bay Protection and Restoration,
74 Fed. Reg. 23099 (May 15, 2009).
[6] Federal Leadership Committee for the Chesapeake Bay, Executive
Order 13508 Strategy for Protecting and Restoring the Chesapeake Bay
Watershed (Washington, D.C.: May 2010).
[7] EPA, Chesapeake Bay Compliance and Enforcement Strategy
(Washington, D.C.: May 2010).
[8] [hyperlink, http://www.gao.gov/products/GAO-06-96].
[9] EPA, Chesapeake Bay Program Office, Strengthening the Management,
Coordination, and Accountability of the Chesapeake Bay Program
(Annapolis, MD: July 2008).
[10] [hyperlink, http://www.gao.gov/products/GAO-08-1033T].
[11] See American Canoe Association v. United States Environmental
Protection Agency, 30 F.Supp.2d 908 (E.D.Va.1998); Kingman Park Civic
Association v. United States Environmental Protection Agency, 84
F.Supp.2d 1 (D.D.C. 1999).
[12] The Chesapeake Bay Foundation is a nongovernmental organization
that works with government, business, and citizens to protect and
restore the bay.
[13] The Watershed Implementation Plans are part of EPA's bay TMDL
accountability framework. The watershed states were expected to
propose how they would distribute allocations of nitrogen, phosphorus,
and sediment among various sectors and demonstrate reasonable
assurance that those allocations will be achieved and maintained in
the phase one Watershed Implementation Plans. In the phase two plans,
the states are expected to identify key local, state, and federal
partners who will be involved in meeting the TMDL; how the states will
work with those partners; and how progress by those partners will be
tracked, among other things. In the phase three plans, the watershed
states are expected to make any midcourse adjustments to pollution
reduction strategies and propose refinements if necessary.
[14] In a lawsuit filed on January 10, 2011, the American Farm Bureau
Federation contended that, among other things, EPA had overstepped its
authority in issuing a bay TMDL. The National Association of Home
Builders filed suit against EPA in June 2011 with similar claims
challenging the TMDL as unlawful. These cases have been consolidated.
[15] The 12 measurable goals are called outcomes in the Strategy. We
refer to outcomes as measurable goals in this report.
[16] We did not evaluate these four supporting strategies, or the 51
actions associated with them, because the four supporting strategies
do not have specific, measurable goals of their own, but rather are
closely tied to achievement of the broad goals.
[17] GAO, Natural Resource Management: Opportunities Exist to Enhance
Federal Participation in Collaborative Efforts to Reduce Conflicts and
Improve Natural Resource Conditions, [hyperlink,
http://www.gao.gov/products/GAO-08-262] (Washington, D.C.: Feb. 12,
2008).
[18] GAO, South Florida Ecosystem Restoration: Substantial Progress
Made in Developing a Strategic Plan, but Actions Still Needed,
[hyperlink, http://www.gao.gov/products/GAO-01-361] (Washington, D.C.:
Mar. 27, 2001), and Agency Performance Plans: Examples of Practices
That Can Improve Usefulness to Decisionmakers, [hyperlink,
http://www.gao.gov/products/GAO/GGD/AIMD-99-69] (Washington, D.C.:
Feb. 26, 1999).
[19] National Research Council, Achieving Nutrient and Sediment
Reduction Goals in the Chesapeake Bay: An Evaluation of Program
Strategies and Implementation (Washington, D.C.: April 2011).
[20] GAO, South Florida Ecosystem Restoration: Task Force Needs to
Improve Science Coordination to Increase the Likelihood of Success,
[hyperlink, http://www.gao.gov/products/GAO-03-345] (Washington, D.C.:
Mar. 18, 2003), and Yellowstone Bison: Interagency Plans and Agencies'
Management Need Improvement to Better Address Bison-Cattle Brucellosis
Controversy, [hyperlink, http://www.gao.gov/products/GAO-08-291]
(Washington, D.C.: Mar. 7, 2008).
[21] Federal Leadership Committee for the Chesapeake Bay, Fiscal Year
2011 Action Plan (Washington, D.C.: Sept. 30, 2010).
[22] EPA is responsible for issuing a report on the state of the bay
ecosystem every 5 years, starting in April 2003, as directed by the
Clean Water Act.
[23] Federal Leadership Committee for the Chesapeake Bay, Executive
Order 13508 Strategy for Protecting and Restoring the Chesapeake Bay
Watershed (Washington, D.C.: May 2010).
[24] The Bay Program is a partnership to direct and conduct the
restoration of the bay at the federal, state, and local levels that
also includes academic institutions and nonprofit organizations.
[25] Federal Leadership Committee for the Chesapeake Bay, Fiscal Year
2011 Action Plan (Washington, D.C.: Sept. 30, 2010).
[End of section]
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